Wisconsin Statutes
Wis. Stat. § 785.02 (2026)
Power of court to punish for contempt of court
✓ current as of July 2026
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785.02785.02 Power of court to punish for contempt of court. A court of record may impose a remedial or punitive sanction for contempt of court under this chapter.
785.02 AnnotationA juvenile was improperly held in contempt of court when the court did not sufficiently consider less restrictive alternative dispositions. A juvenile may be found in contempt and incarcerated subject to enumerated conditions. In Interest of D.L.D. 110 Wis. 2d 168, 327 N.W.2d 682 (1983).
785.02 AnnotationA contemnor whose liberty interests are at risk must be given an opportunity to show the court that the failure to comply with purge conditions was not willful and intentional. V.J.H. v. C.A.B. 163 Wis. 2d 833, 472 N.W.2d 939 (Ct. App. 1991).
785.02 AnnotationNecessary conditions for imposition of summary contempt are enumerated. Extreme intoxication of a criminal defendant at a sentencing hearing was properly punished by summary contempt. Shepard v. Outagamie County Circuit Court, 189 Wis. 2d 279, 525 N.W.2d 769 (Ct. App. 1994).
785.02 AnnotationWhen dealing with a payment as a remedial sanction to compensate a party for a loss suffered as a result of contempt, it is possible for there to be a purge condition without a sanction or for the purge condition to be the same as the sanction. Frisch v. Henrichs, 2007 WI 102, 304 Wis. 2d 1, 736 N.W.2d 85, 05-0534.
785.02 AnnotationCourts may hold juveniles in contempt of court. The limited circumstances under which the sanction of imprisonment may be imposed is discussed. 70 Atty. Gen. 98.
785.02 AnnotationContempt of court: Wisconsin’s erasure of the blurred distinction between civil and criminal contempt. 66 MLR 369 (1983).
Notes of Decisions
Cited in 19
cases (9 in the last 5 years), 1987–2026 · leading case: State v. Ndina, 2009 WI 21 (Wis. 2009).
State v. Ndina, 2009 WI 21 (Wis. 2009). “15 and § 785.02. Wisconsin Stat. § 906.15 provides in full as follows: (1) At the request of a party, the judge or a circuit court commissioner shall order witnesses excluded so that they cannot hear the testimony of other witnesses.”
Frisch v. Henrichs, 2007 WI 102 (Wis. 2007). “" Note (Wis.Stat. § 785.02), § 11, ch. 257, Laws of 1979, at 1355.”
Christensen v. Sullivan, 2009 WI 87 (Wis. 2009). “According to that interpretation, two outcomes are possible: (1) the circuit court would be required to impose remedial sanctions, thus depriving the court of its discretion under Wis. Stat. § 785.02 ; or (2) the circuit court would refuse to impose remedial sanctions and the…”
State v. Ronald Knipfer, 2015 WI 3 (Wis. 2015). “15 See Wis. Stat. § 785.02 (regarding the power of the court to punish for contempt of court); see also Wis.”
Timothy Zignego v. Wisconsin Elections Comm'n, 2021 WI 32 (Wis. 2021). “A punitive sanction is "imposed to punish a past contempt of court for the purpose of upholding the authority of the court," while a remedial sanction is "imposed for the purpose of terminating a continuing contempt of court.”
In Re Marriage of Benn v. Benn, 602 N.W.2d 65 (Wis. Ct. App. 1999). “See §§ 785.02 and 785.04(1), Stats. And finally, the circuit court's award of attorney fees under § 785.”
State Ex Rel. Larsen v. Larsen, 465 N.W.2d 225 (Wis. Ct. App. 1990). “Section 785.02, Stats. Such sanctions are "imposed for the purpose of terminating a continuing contempt of court.”
Gleiss v. Newman, 415 N.W.2d 845 (Wis. Ct. App. 1987). “Sections 785.02, 785.03, 785.04, 767.245, Stats.”
J.W. v. M.W.G., 426 N.W.2d 112 (Wis. Ct. App. 1988). “Upon such a disobedience, a court is authorized under sec. 785.02, Stats., to impose remedial or punitive sanctions as punishment for the contempt.”
In Re Paternity of JLV, 426 N.W.2d 112 (Wis. Ct. App. 1988). “Upon such a disobedience, a court is authorized under sec. 785.02, Stats., to impose remedial or punitive sanctions as punishment for the contempt.”
Michael S. Eisenga v. Clare A. Hawthorne (Wis. Ct. App. 2023). “§ 785.02, which are imposed “for the purpose of terminating a continuing contempt of court,” WIS.”
William Russell Roberts v. Andrea Ann Roberts (Wis. Ct. App. 2020). “§ 785.02. A remedial sanction means “a sanction imposed for the purpose of terminating a continuing contempt of court.”
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